2021-11-12T11:51:02-06:00 2021-06-30 366055558 GRANT THORNTON LLP 171 N CLARK ST SUITE 200 CHICAGO IL 60601 990 2020-07-01 362960981 NATIONAL FUTURES ASSOCIATION NATI 3127811300 300 S RIVERSIDE PLAZA NO 1800 CHICAGO IL 606066615 DAVID HAWRYSZ SR VP, CFO, TREASURER 3127811300 2021-11-12 1 DAVID HAWRYSZ 999009999 BRIDGET T ROCHE P00666837 3128560200 3 AAL1 IAL1 2020 2022-09-23 18:48:47Z NFA DAVID HAWRYSZ 300 S RIVERSIDE PLAZA NO 1800 CHICAGO IL 606066615 110867239 0 X WWW.NFA.FUTURES.ORG X 1976 DE NFA IS A SELF-REGULATORY MEMBERSHIP ORGANIZATION FORMED TO MONITOR (CONTINUED IN SCHEDULE O) AND MAINTAIN THE INTEGRITY OF THE DERIVATIVES TRADING INDUSTRY. 29 29 591 0 0 0 0 0 118871659 109745548 2001524 1121691 0 0 120873183 110867239 0 0 0 0 81714093 84740564 0 0 0 24538476 25073576 106252569 109814140 14620614 1053099 160552859 169694362 26589398 28731218 133963461 140963144 X AS A CONGRESSIONALLY AUTHORIZED SELF-REGULATORY ORGANIZATION, NATIONAL FUTURES ASSOCIATION (NFA) IS THE SELF-REGULATORY ORGANIZATION FOR THE U.S. DERIVATIVES INDUSTRY, INCLUDING EXCHANGE TRADED FUTURES, RETAIL OFF-EXCHANGE FOREIGN CURRENCY (FOREX) AND (CONTINUED IN SCHEDULE O) OTC DERIVATIVES (SWAPS). NFA HAS DEVELOPED AND ENFORCES RULES, PROVIDES PROGRAMS AND OFFERS SERVICES THAT SAFEGUARD MARKET INTEGRITY, PROTECT INVESTORS AND HELP OUR MEMBERS MEET THEIR REGULATORY RESPONSIBILITIES. 0 0 0 0 0 REGISTRATIONNFA SCREENS ALL FIRMS AND INDIVIDUALS WISHING TO REGISTER WITH THE CFTC AND BECOME NFA MEMBERS. NFA'S REGISTRATION DEPARTMENT PROCESSED 360 FIRM REGISTRATIONS AND OVER 6,600 INDIVIDUAL REGISTRATIONS.REGISTRATION INVESTIGATION CASES NFA'S REGISTRATION INVESTIGATIONS GROUP OPENED APPROXIMATELY 1,200 CASES. THESE INVESTIGATION CASES ARE DUE TO INFORMATION OBTAINED DURING NFA'S BACKGROUND CHECKS.(CONTINUED IN SCHEDULE O)INFORMATION CENTER NFA'S INFORMATION CENTER - A SERVICE NFA OFFERS TO MEMBERS AND THE INVESTING PUBLIC - RECEIVED MORE THAN 25,000 CALLS AND RESPONDED TO NEARLY 6,000 EMAILS.ENFORCEMENT ACTIONS ENFORCEMENT OF NFA RULES IS CRITICAL TO THE EFFECTIVENESS OF THE SELF-REGULATORY PROCESS. IN FISCAL YEAR 2021: NFA'S BUSINESS CONDUCT COMMITTEE ISSUED 17 COMPLAINTS AGAINST 26 RESPONDENTS. A NUMBER OF THESE CASES INVOLVED MEMBERS AND ASSOCIATES WHO FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE AND/OR FAILED TO ADEQUATELY SUPERVISE THEIR EMPLOYEES AND OPERATIONS.NFA'S DISCIPLINARY PANELS ISSUED 26 DECISIONS AND ORDERED 15 MEMBERSHIP BARS AND 7 MEMBERSHIP SUSPENSIONS, AND NFA IMPOSED OVER $1 MILLION IN FINES. 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 0 1 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 107 0 1 591 1 0 0 0 0 0 0 0 0 X 29 29 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 CA X DAVID HAWRYSZ 3127811300 300 SOUTH RIVERSIDE PLAZA SUITE CHICAGO IL 60606 THOMAS SEXTON PRESIDENT AND CEO 40.00 0.00 X 820264 0 64344 REGINA THOELE SENIOR VICE PRESIDENT 40.00 0.00 X 617235 0 63399 CAROL WOODING VP, GC, AND SECRETARY 40.00 0.00 X 576388 0 61342 EDWARD DASSO VICE PRESIDENT 40.00 0.00 X 553777 0 75925 TIMOTHY MCHENRY VICE PRESIDENT 40.00 0.00 X 532093 0 63329 DAVID HAWRYSZ SR. VP, CFO, AND TREASURER 40.00 0.00 X 504106 0 64398 KAREN WUERTZ SENIOR VICE PRESIDENT 40.00 0.00 X 455834 0 61324 MICHAEL OTTEN VICE PRESIDENT 40.00 0.00 X 476689 0 38943 JOSEPH HAWRYSZ MANAGING DIRECTOR, COMPLIANCE 40.00 0.00 X 328551 0 52898 JOSEPH ZANGRI MANAGING DIRECTOR, EXAMS OTC 40.00 0.00 X 327309 0 48837 THOMAS GISONDA MANAGING DIRECTOR, OTC DERIVATIVES 40.00 0.00 X 317639 0 47772 ALLESSANDRA RICCARDI MANAGING DIRECTOR, OTC DERIVATIVES 40.00 0.00 X 301502 0 54542 DANIEL DRISCOLL SPECIAL ADVISOR 40.00 0.00 X 284694 0 66556 ADRIANNA JOVES ASSOCIATE COUNSEL 40.00 0.00 X 313746 0 34295 LAUREN BRINATI VP STRATEGIC AFFAIRS 40.00 0.00 X 300137 0 42540 NANCY C BOHANON VICE PRESIDENT, HR 40.00 0.00 X 266274 0 46600 YVETTE CHRISTMAN VICE PRESIDENT 40.00 0.00 X 271044 0 39167 DOUGLAS HARRIS BOARD MEMBER 1.00 0.00 X 43500 0 0 RONALD FILLER BOARD MEMBER 1.00 0.00 X 42000 0 0 RONALD OPPENHEIMER BOARD MEMBER 1.00 0.00 X 42000 0 0 MICHAEL MOSKOW BOARD MEMBER 1.00 0.00 X 41500 0 0 TODD PETZEL BOARD MEMBER 1.00 0.00 X 40000 0 0 CHARLES NASTRO BOARD MEMBER - THRU 2/2021 1.00 0.00 X 26000 0 0 MICHAEL SCHAEFER BOARD MEMBER 1.00 0.00 X 22000 0 0 JIM MARSHALL BOARD MEMBER 1.00 0.00 X 21500 0 0 ARTHUR HAHN BOARD MEMBER 1.00 0.00 X 20000 0 0 MARY MCDONNELL BOARD MEMBER 1.00 0.00 X 20000 0 0 DOUGLAS BRY BOARD MEMBER 1.00 0.00 X 16000 0 0 MAUREEN DOWNS CHAIRPERSON 1.00 0.00 X 16000 0 0 DAVID GOONE BOARD MEMBER 1.00 0.00 X 16000 0 0 ERNEST JAFFARIAN BOARD MEMBER 1.00 0.00 X 16000 0 0 THOMAS KADLEC BOARD MEMBER 1.00 0.00 X 16000 0 0 DON THOMPSON VICE CHAIR 1.00 0.00 X 16000 0 0 MICHAEL BURKE BOARD MEMBER 1.00 0.00 X 14000 0 0 JOHN SANDNER BOARD MEMBER - THRU 3/2021 1.00 0.00 X 14000 0 0 MARK BAGAN BOARD MEMBER 1.00 0.00 X 10000 0 0 MARIA CHIODI BOARD MEMBER 1.00 0.00 X 10000 0 0 SETH BENDER BOARD MEMBER 1.00 0.00 X 8000 0 0 GERALD CORCORAN BOARD MEMBER 1.00 0.00 X 8000 0 0 MARTIN LUECK BOARD MEMBER 1.00 0.00 X 8000 0 0 SCOTT STEWART BOARD MEMBER 1.00 0.00 X 8000 0 0 NICOLA WATSON BOARD MEMBER 1.00 0.00 X 8000 0 0 MARIAM RAFI BOARD MEMBER 1.00 0.00 X 6000 0 0 MARK MAURER BOARD MEMBER - AS OF 8/2020 1.00 0.00 X 4000 0 0 CHARLOTTE MCLAUGHLIN BOARD MEMBER 1.00 0.00 X 4000 0 0 MICHAEL DAWLEY BOARD MEMBER - AS OF 2/2021 1.00 0.00 X 2000 0 0 HECTOR FERNANDEZ BOARD MEMBER - THRU 8/2020 1.00 0.00 X 2000 0 0 JULIE HOLZRICHTER BOARD MEMBER - AS OF 3/2021 1.00 0.00 X 0 0 0 WILLIAM MCCOY BOARD MEMBER 1.00 0.00 X 0 0 0 7767782 0 926211 320 1 1 0 POLARIS SOLUTIONS LLC 6800 FAIRVEIW AVE DOWNERS GROVE IL 60516 COMPUTER SUPPORT 865630 ERNST & YOUNG LLP 155 N UPPER WACKER DRIVE CHICAGO IL 60606 ACCOUNTING SERVICES 390000 JENNER & BLOCK LLP 353 N CLARK STREET CHICAGO IL 60654 LEGAL CONSULTING 337074 CLUNE CONSTRUCTION CO 10 S RIVERSIDE PLAZA SUITE 2200 CHICAGO IL 60606 CONSTRUCTION SERVICES 299783 DELTA STRATEGY GROUP LLC 600 PENNSYLVANIA AVE SE SUITE 300 WASHINGTON DC 20003 CONSULTING SERVICES 180781 12 ASSESS. FEES & MARKET SERV. REV. 900099 63970526 63970526 MEMBERSHIP DUES 900099 42495683 42495683 REGULATORY FINES 900099 1539000 1539000 REGISTRATION & TESTING FEES 900099 1041686 1041686 ARBITRATION REVENUE 900099 447237 447237 251416 251416 109745548 1121691 1121691 110867239 109745548 0 1121691 7197418 58245522 6003624 8684672 4609328 808503 125085 4401416 44600 1319898 5747255 5002261 154594 27750 6257107 19 EDUCATION & RECRUITMENT 635118 DUES & SUBSCRIPTIONS 549970 109814140 12140201 25891184 52274598 39903906 1248669 1879816 1565987 2980692 33843757 23715360 11565388 10128397 76315928 83483274 5442088 5427093 160552859 169694362 5141285 6277887 8813706 9553862 12634407 12899469 26589398 28731218 X 133963461 140963144 133963461 140963144 160552859 169694362 X 1053099 5556306 390278 X 0 1 X 1 0 0 0 0 106466209 13562 13562 0 13562 1 36310418 319975296 11205721 367491435 0 12036180 9599667 2436513 10816294 4131130 6685164 10991283 9984563 1006720 10128397 POST RETIREMENT 12005605 ALL OTHER LIABILITIES 889586 UNCLAIMED DISBURSEMENT 4278 12899469 X 116423545 5556306 5556306 110867239 0 110867239 109814140 0 109814140 0 109814140 PART IV, LINE 1B: AGENT, TRUSTEE, CUSTODIAN, ETC. ARRANGEMENT THE COMMODITY FUTURES TRADING COMMISSION (CFTC) PERIODICALLY ASKS FEDERAL COURTS TO APPOINT NFA TO SERVE AS A COURT-APPOINTED MONITOR IN RESTITUTION JUDGMENTS AWARDED IN CFTC CASES BROUGHT BEFORE THE COURTS. AS MONITOR, NFA ASSISTS IN PROVIDING HARMED INVESTORS IDENTIFIED BY THE COURT ORDER WITH THEIR PRO-RATA SHARE OF RESTITUTION. THE RESTITUTION FUNDS ARE PLACED IN QUALIFIED SETTLEMENT FUNDS (QSF) WHICH ARE SEPARATE LEGAL ENTITIES ESTABLISHED AND TITLED PURSUANT TO A FEDERAL COURT ORDER. QSFS ARE ORDINARILY SUBJECT TO THE CONTINUING JURISDICTION OF THE FEDERAL COURT. NFA HAS CHECK WRITING AUTHORITY FOR THE QSFS. PART X, LINE 2: LIABILITY FOR UNCERTAIN TAX POSITION (ASC 740) THE ASSOCIATION FOLLOWS GUIDANCE THAT CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS GUIDANCE PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN ONLY BE RECOGNIZED IN THE FINANCIAL STATEMENTS IF THE POSITION IS MORE LIKELY THAN NOT TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE ASSOCIATION IS EXEMPT FROM FEDERAL INCOME TAX UNDER INTERNAL REVENUE CODE (IRC) SECTION 501(C)(6), THOUGH IT IS SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. THE ASSOCIATION HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS, AND THERE ARE NO INTEREST AND PENALTIES RECOGNIZED IN THE ACCOMPANYING FINANCIAL STATEMENTS. X 1 1 X X X 0 0 0 THOMAS SEXTON PRESIDENT AND CEO 727660 0 85000 0 7604 0 39500 0 34190 0 893954 0 0 0 REGINA THOELE SENIOR VICE PRESIDENT 536975 0 72500 0 7760 0 39500 0 32399 0 689134 0 0 0 CAROL WOODING VP, GC, AND SECRETARY 493601 0 75000 0 7787 0 39500 0 22442 0 638330 0 0 0 EDWARD DASSO VICE PRESIDENT 486953 0 62500 0 4324 0 39500 0 36425 0 629702 0 0 0 TIMOTHY MCHENRY VICE PRESIDENT 450232 0 75000 0 6861 0 39500 0 23829 0 595422 0 0 0 DAVID HAWRYSZ SR. VP, CFO, AND TREASURER 444492 0 52500 0 7114 0 39500 0 34229 0 577835 0 0 0 KAREN WUERTZ SENIOR VICE PRESIDENT 390441 0 58000 0 7393 0 39500 0 31068 0 526402 0 0 0 MICHAEL OTTEN VICE PRESIDENT 443338 0 30000 0 3351 0 17100 0 21843 0 515632 0 0 0 JOSEPH HAWRYSZ MANAGING DIRECTOR, COMPLIANCE 309228 0 17850 0 1473 0 31100 0 21798 0 381449 0 0 0 JOSEPH ZANGRI MANAGING DIRECTOR, EXAMS OTC 312239 0 13000 0 2070 0 28129 0 20708 0 376146 0 0 0 THOMAS GISONDA MANAGING DIRECTOR, OTC DERIVATIVES 302121 0 12500 0 3018 0 25978 0 21794 0 365411 0 0 0 ALLESSANDRA RICCARDI MANAGING DIRECTOR, OTC DERIVATIVES 286788 0 13500 0 1214 0 31100 0 23442 0 356044 0 0 0 DANIEL DRISCOLL SPECIAL ADVISOR 252787 0 27500 0 4407 0 31775 0 34781 0 351250 0 0 0 ADRIANNA JOVES ASSOCIATE COUNSEL 299238 0 14000 0 508 0 31100 0 3195 0 348041 0 0 0 LAUREN BRINATI VP STRATEGIC AFFAIRS 274482 0 25000 0 655 0 31755 0 10785 0 342677 0 0 0 NANCY C BOHANON VICE PRESIDENT, HR 228653 0 35000 0 2621 0 25688 0 21512 0 313474 0 0 0 YVETTE CHRISTMAN VICE PRESIDENT 231910 0 35000 0 4134 0 27091 0 12076 0 310211 0 0 0 PART I, LINE 1A HEALTH CLUB DUES OR INITIATION FEES HEALTH CLUB DUES PROVIDED TO CAROL WOODING, DAVID HAWRYSZ, EDWARD DASSO, KAREN WUERTZ, MICHAEL OTTEN, REGINA THOELE, TIMOTHY MCHENRY, AND THOMAS SEXTON, OFFICERS, IN THE AMOUNT OF $4,548 WERE REPORTED AS COMPENSATION ON FORM W-2. THIS OPTION WAS NOT FULLY UTILIZED DURING THIS PERIOD. NFA CURRENTLY DOES NOT OFFER FIRST CLASS TRAVEL ON OVERSEAS BUSINESS TRIPS, NFA OFFICERS MAY ELECT TO FLY BUSINESS CLASS. FORM 990, PART VI, SECTION A, LINE 6 MEMBERS OR STOCKHOLDERS MEMBERS ARE DIVIDED INTO CATEGORIES BASED UPON THEIR REGISTRATION TYPE WITH THE COMMODITY FUTURES TRADING COMMISSION (CFTC). THE MEMBERSHIP CATEGORIES INCLUDE: CONTRACT MARKETS, FUTURES COMMISSION MERCHANTS AND LEVERAGED TRANSACTION MERCHANTS, INTRODUCING BROKERS, RETAIL FOREIGN EXCHANGE DEALERS, SWAP DEALERS, MAJOR SWAP PARTICIPANTS, COMMODITY POOL OPERATORS AND COMMODITY TRADING ADVISORS. MEMBERS ELECT REPRESENTATIVES FROM THEIR RESPECTIVE CATEGORIES TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS ELECTS PUBLIC DIRECTORS (NON-MEMBERS) TO THE BOARD OF DIRECTORS. OTHER THAN A CHANGE IN THE ARTICLES OF INCORPORATION, MEMBERS GENERALLY DO NOT APPROVE SIGNIFICANT DECISIONS OF THE GOVERNING BODY. UPON DISSOLUTION, THE NET ASSETS OF NFA, AFTER PAYMENT OF LIABILITIES, SHALL BE DISTRIBUTED TO THE MEMBERS IN PROPORTION TO THE DUES AND ASSESSMENTS PREVIOUSLY PAID. FORM 990, PART VI, SECTION A, LINE 7A MEMBERS OR STOCKHOLDERS WHO MAY ELECT A VACANCY ON THE BOARD THAT OCCURS BEFORE THE EXPIRATION OF A DIRECTOR'S TERM OR BECAUSE ADDITIONAL DIRECTORS IN EXISTING OR NEW MEMBER CATEGORIES ARE REQUIRED SHALL BE FILLED (FOR THE UNEXPIRED TERM) BY AN ELIGIBLE INDIVIDUAL ELECTED BY MAJORITY VOTE OF THE REMAINING DIRECTORS WHO REPRESENT THE CATEGORY OF MEMBERS IN WHICH THE VACANCY OCCURRED. SEE FORM 990, PART VI, LINE 6 ABOVE FOR THE NATURE OF THE VOTING RIGHTS. FORM 990, PART VI, SECTION A, LINE 7B DECISIONS SUBJECT TO APPROVAL A CHANGE IN NFA'S ARTICLES OF INCORPORATION REQUIRES APPROVAL OF THE MAJORITY OF THOSE VOTING IN EACH MEMBERSHIP CATEGORY. FORM 990, PART VI, SECTION B, LINE 11B FORM 990 REVIEW PROCESS NFA TAX RETURNS ARE PREPARED BY A NATIONAL OUTSIDE PUBLIC ACCOUNTING FIRM. PRIOR TO FILING THE FORM 990 IT IS REVIEWED AND APPROVED BY NFA'S AUDIT COMMITTEE (THREE MEMBERS). THE REVIEW INVOLVES AN IN-DEPTH PRESENTATION BY NFA STAFF TO THE COMMITTEE. THE COMMITTEE WILL ALSO REVIEW THE OVERALL ACCURACY AND COMPLETENESS OF THE FORM 990. PRIOR TO FILING THE FORM 990, THE DRAFT RETURN IS PROVIDED TO THE REMAINING VOTING MEMBERS OF NFA'S GOVERNING BODY. NFA'S CFO ALSO REVIEWED THE 990 FOR OVERALL ACCURACY AND COMPLETENESS PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT AT NFA'S BOARD OF DIRECTORS' ANNUAL MEETING, NFA'S GENERAL COUNSEL PRESENTS, IN WRITING, NFA'S POLICY AND PROCEDURE ON CONFLICTS AND DUALITIES OF INTEREST ("POLICY"). EACH DIRECTOR IS SUBSEQUENTLY REQUIRED TO SIGN A WRITTEN STATEMENT THAT DISCLOSES ANY AFFILIATION THAT MAY GIVE RISE TO POTENTIAL CONFLICTS AND DUALITIES OF INTEREST UNDER THE POLICY. THE WRITTEN STATEMENT ALSO ACKNOWLEDGES THAT THE DIRECTOR HAS RECEIVED, READ AND UNDERSTOOD, AND AGREES TO ABIDE BY NFA'S POLICY; AND THAT THE DIRECTOR WILL DISCLOSE, AS IT OCCURS, ANY AFFILIATION THAT MAY GIVE RISE TO A CONFLICT OR DUALITY OF INTEREST UNDER THE POLICY. NFA'S GENERAL COUNSEL REVIEWS AND MAINTAINS THESE WRITTEN STATEMENTS AND CONSIDERS THEM AS MATTERS UPON WHICH THE BOARD ACTS ARISE. IF ANY DIRECTOR HAS AN AFFILIATION THAT MAY GIVE RISE TO A CONFLICT OR DUALITY OF INTEREST UNDER THE POLICY IN CONNECTION WITH A MATTER COMING BEFORE THE BOARD, NFA'S GENERAL COUNSEL BRINGS THE AFFILIATION TO THE BOARD'S ATTENTION IN THE EVENT THAT THE DIRECTOR DOES NOT. NFA'S STAFF IS REQUIRED TO ADHERE TO A CONFLICT OF INTEREST POLICY, WHICH IS MONITORED BY HUMAN RESOURCES. STAFF ANNUALLY COMPLETE THEIR CONFLICT OF INTEREST QUESTIONNAIRES, WHICH HUMAN RESOURCES REVIEWS AND MAINTAINS. IF ANY CONFLICTS ARISE, THE GENERAL COUNSEL DISCUSSES THE POTENTIAL CONFLICT WITH THE STAFF MEMBER, AND DOCUMENTS ACTIONS TAKEN; WHETHER DISPOSAL OF THE INTEREST OR ANY DISCIPLINARY ACTION UNDER THE CODE OF PROFESSIONAL CONDUCT IS WARRANTED DEPENDS ON THE LEVEL OF CONFLICT UNDER REVIEW. FORM 990, PART VI, SECTION B, LINE 15 PROCESS FOR DETERMINING COMPENSATION THE COMPENSATION COMMITTEE IS COMPRISED OF THREE VOTING MEMBERS OF THE BOARD. FOR ALL OFFICERS EXCEPT THE CEO, THE CEO COLLABORATES WITH THE COMPENSATION COMMITTEE TO DETERMINE THE OFFICERS' COMPENSATION. THE CEO AND THE COMPENSATION COMMITTEE DISCUSS EACH OFFICER'S CONTRIBUTION TO THE ORGANIZATION; THEY REVIEW COMPARABLE MARKET DATA PROVIDED BY NFA'S HUMAN RESOURCE DEPARTMENT AND DELIBERATE COMPENSATION RECOMMENDATIONS WHICH ARE DOCUMENTED AND PRESENTED TO THE EXECUTIVE COMMITTEE. THE SAME METHOD, AS DESCRIBED ABOVE, IS USED IN DETERMINING THE CEO'S COMPENSATION, ONLY THE CEO IS NOT PART OF THE PROCESS. THE EXECUTIVE COMMITTEE REVIEWS THE COMPENSATION COMMITTEE'S PROPOSED RECOMMENDATION AND EITHER ACCEPTS OR ADJUSTS THE PROPOSAL. THE EXECUTIVE COMMITTEE THEN MAKES ITS RECOMMENDATION TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS EITHER APPROVES OR MODIFIES THE EXECUTIVE COMMITTEE'S RECOMMENDATION. THE BOARD THEN APPROVES FINAL COMPENSATION FOR OFFICERS. THE ORGANIZATION CONTEMPORANEOUSLY DOCUMENTS AND MAINTAINS RECORDS OF DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENTS OF THE OFFICERS. FORM 990, PART VI, SECTION C, LINE 19 HOW DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC THE ORGANIZATION MAKES ITS BYLAWS, ARTICLES OF INCORPORATION AND FINANCIAL STATEMENTS AVAILABLE ON ITS WEBSITE OR UPON WRITTEN REQUEST. THE CONFLICTS OF INTEREST POLICY IS AVAILABLE UPON REQUEST. FORM 990, PART XI, LINE 9: NET PERIODIC BENEFIT COSTS 390,278.